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Notice 2020-61: Special rules for single-employer defined benefit pension plans (COVID-19)

Rules for single-employer defined benefit pension plans

The IRS today released an advance version of Notice 2020-61 that provides guidance—in a “question and answer” (Q&A) format—concerning the special rules relating to funding of single-employer defined benefit pension plans, and related benefit limitations, as enacted by the “Coronavirus Aid, Relief, and Economic Security Act” (CARES Act) (Pub. L. No. 116-136).

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Read Notice 2020-61 [PDF 109 KB]

Background

The CARES Act—one of a series of laws enacted to provide relief in response to the coronavirus (COVID-19) pandemic—provides single-employer pension plan sponsors additional time to meet funding obligations. The deadline for minimum required contributions, including estimated payments, to single-employer pension plans that would otherwise be due during 2020 was extended to January 1, 2021. Minimum required contribution payments that are delayed will be due with applicable interest accruing from the original due date through the date of payment.

The CARES Act further provides that plan sponsors of single-employer pension plans may elect to treat the plan’s adjusted funding target attainment percentage (AFTAP) for the last plan year ending before January 1, 2020, as the AFTAP for plan years which include calendar year 2020.

Notice 2020-61

Today’s notice includes guidance in 18 Q&As regarding the relief provided under the CARES Act.

Notice 2020-61 states in Q&A-11 that the extended due date under the CARES Act does not change the date by which a contribution must be made in order to be deducted for a tax year under section 404(a)(6), which permits a deduction for the prior tax year if the payment is on account of that tax year and is made no later than the due date for filing the return for that tax year (including extensions). 

Notice 2020-61 provides special instructions for actuaries completing Schedule SB of Form 5500 in light of the changes made by the CARES Act. 

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